TPO Ban: What It Means for the Gel Nail Industry

Posted November 12, 2025

Recently, the European Union (EU) announced a ban on Trimethylbenzoyl Diphenylphosphine Oxide (TPO), one of the chemicals used as a photoinitiator in gel nail polishes. This ban specifically targets TPO containing products, applying to certain products such as gel nail polishes. The decision has raised questions among Canadian beauty brands and manufacturers about whether similar restrictions could soon affect Canada’s cosmetic industry.

What Is TPO and Why It’s Used in Gel Nail Polish

Trimethylbenzoyl Diphenylphosphine Oxide (TPO) is a photoinitiator used in gel nail polish formulations. Manufacturers must determine the optimal amount of TPO to ensure the polish cures properly under UV or LED light, giving manicures their durable, glossy finish. Information published in some animal studies indicating that ingestion of high doses of TPO could lead to reproductive toxic effects have led to recent regulatory discussion.

EU’s Decision: Understanding the TPO Ban

Under the EU CLP (Classification, Labelling and Packaging) regulation, which provides the regulatory framework for classifying chemicals based on their hazard potential, TPO was classified as a CMR Category 1B reproductive toxicant. This classification requires the ingredient to be added to the list of prohibited cosmetic substances, leading to the ban effective September 1, 2025.

The European Commission proposed and enacted the ban on TPO in cosmetics, working with industry stakeholders and regulatory bodies to ensure safety standards are met.

Key Details of the EU TPO Ban:

New gel nail products containing TPO cannot enter the EU market.
Existing products with TPO can no longer be sold after the effective date.
The ban only applies to nail products, not other industries like dental materials.

The ban will be enforced uniformly across all EU member states to ensure consistent regulation and market surveillance.

Will the TPO Ban Affect Canada?

Currently, Health Canada has not announced any plans to ban TPO in products intended for use as cosmetics, such as gel nail polishes. TPO-containing products currently marketed in Canada remain compliant unless Health Canada updates its regulations. The EU versus Canadian response highlights how regulatory approaches vary across different regulatory domains.

Hazard-Based vs. Risk-Based Regulation

EU Approach (Hazard-Based): Focuses on whether a substance can cause harm, regardless of exposure level. → Studies on animals were used to determine that high concentrations of TPO could affect reproduction.
Canada’s Approach (Risk-Based): Evaluates the likelihood and severity of harm under real-world exposure. → Health Canada found insufficient evidence that TPO in nail products poses a significant risk.

What It Means for Cosmetic Companies selling in Canada

For now, it’s business as usual in Canada.

You can continue to manufacture, import, and sell gel nail polishes containing TPO as long as they comply with Canadian Cosmetic Regulations. It is essential to review the INCI list to ensure your products do not contain restricted or banned ingredients and remain compliant with regulatory requirements.

Manufacturers and importers must regularly consult the Cosmetic Ingredient Hotlist to ensure their gel nail polish and other nail products comply with current Canadian regulations.

Cosmetic Ingredient Hotlist

The Cosmetic Ingredient Hotlist is an essential reference for anyone involved in the formulation, import, or sale of cosmetic products in Canada, including gel nail polish. Maintained by Health Canada, this list identifies substances that are either prohibited or restricted in cosmetic products due to their potential health risks, such as skin irritation or sensitization. For example, Benzoyl peroxide is permitted for use only in nail products for professional use because risk of causing skin irritation increases if used incorrectly. In contrast, TPO is currently not listed in either section (prohibited or restricted) of the Hotlist, meaning Health Canada has not currently outlined any specific conditions of use for this ingredient.

Ultimately, the Cosmetic Ingredient Hotlist serves as a proactive tool for managing risk and maintaining compliance in the fast-evolving world of cosmetic products. Whether you are developing new gel formulations or reviewing existing product lines, referencing the Hotlist is a critical step in safeguarding both consumer health and your business’s reputation. By staying informed about which ingredients are restricted or prohibited, companies can avoid costly recalls and ensure their products remain safe and marketable in Canada.

How Dell Tech Can Help

At Dell Tech Laboratories, we provide a comprehensive regulatory solution to help cosmetic companies navigate complex Canadian regulatory requirements. Our range of services includes regulatory consulting, compliance support, and industry guidance tailored to your needs. We are fully prepared to assist clients in adapting to regulatory changes, including the TPO ban, ensuring a smooth transition. Our team consists of professional regulatory experts who understand the unique requirements of professional use products and the importance of trained professionals in the cosmetics industry.

Whether you’re notifying a TPO-based gel polish or launching a TPO-free alternative, our consultants provide expert guidance on:

Cosmetic product classification
Cosmetic notifications
Ingredient assessments and compliance

📞 Contact us to ensure your products meet all Health Canada cosmetic safety standards.

the safety of nail products depends on careful formulation, adherence to regulations, and awareness of potential health risks. By staying informed and following Health Canada’s guidance, both manufacturers and consumers can help ensure that gel nail applications remain a safe and enjoyable part of the beauty industry.

DELL TECH HAS PROVIDED PROFESSIONAL, CONFIDENTIAL CONSULTING SERVICES TO THE SPECIALTY CHEMICAL INDUSTRY IN CANADA, THE USA, EUROPE AND ASIA FOR THE LAST 40 YEARS.